Owner and Data Controller
Veronique Bogliolo Friedman d/b/a Bogliolo Coaching & Consulting
New York, NY 10024
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
- Usage Data
- First name, last name, phone number and email address.
Personal Data may be freely provided by the User, or, in case of usage data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide it may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, users are free not to communicate this Data without consequences to the availability or the functioning of the service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the owner.
Mode and place of processing the Data
Methods of processing
The owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the owner. The updated list of these parties may be requested from the owner at any time.
Legal basis of processing
The owner may process Personal Data relating to users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: under some legislations the owner may be allowed to process Personal Data until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the owner;
- processing is necessary for the purposes of the legitimate interests pursued by the owner or by a third party.
In any case, the owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the user’s location, data transfers may involve transferring the user’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the owner to safeguard their Data.
If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with the owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Personal Data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.
The owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the user is collected to allow the owner to provide its services, as well as for the following purposes:
- Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the owner to monitor and analyze web traffic and can be used to keep track of user behavior.
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
- Personal Data collected: Cookies; Usage Data.
Contacting the User
By filling in the contact form with their Data, the user authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
- Personal Data collected: email address; first name; last name and phone number.
The rights of Users
Users may exercise certain rights regarding their Data processed by the owner. In particular, users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the user is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the owner is processing Personal Data for direct marketing purposes, users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month.
Additional information about Data collection and processing
The user’s Personal Data may be used for legal purposes by the owner in court or in the stages leading to possible legal action arising from improper use of this Website or the related services.The user declares to be aware that the owner may be required to reveal personal data upon request of public authorities.
Additional information about user’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (system logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Latest revision: November 2019
What is a cookie?
A cookie is a small file that can be placed on your device that allows us to recognize and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our Website, we may collect anonymized information about our visitors through cookies.
- Understanding how you use this Website, via Google Analytics (third-party cookie).
- Protecting our Website from cyberattacks and increasing it speed, via CloudFlare (third-party cookie).
- Remembering your cookie choice (first-party cookie).
What type of cookies do we use?
We use two types of cookies, which we describe in this section:
Essential – cookies that are essential to provide you with services you have requested, for example the cookie that makes it possible for you to choose whether you accept cookies. If you set your browser to block these cookies, then this function will not work for you and we won’t be able to save your preference about cookies.
Performance – cookies which measure how often you visit our Website and how you use it. We use this information to get a better sense of how users engage with our content and to improve our Website, so that they have a better experience. For example, we collect information about which of our pages are most frequently visited, and by which types of users. We use third-party cookies set by Google Analytics, which gives us information such as your journey between pages. Your IP address is anonymized.
How can you configure or block cookies?
You can switch off the cookies set by Google Analytics by clicking on the “Configure cookies” link in the footer below, then selecting “Decline”. You may need to do this again each time you use a different IP address or device.
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